SEBI adjudication orders on illiquid stock options at BSE (2022 batch)

Judgment entered

✓ Checked against the primary document on October 8, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, in a single reading of the order; an independent second reading of 60 SEBI records agreed on every field for 56, the four misses being penalty amounts; a later sample of 50 of the SEBI records added on 9 October agreed on every field for 46. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

Report an error in this record (sebi-illiquid-stock-options-bse-2022-matched-orders) by email

SEBI adjudicating officers issued 368 orders in 2022, one per noticee, penalising entities whose reversal trades in illiquid BSE stock options in 2014-15 were found to be non-genuine under the PFUTP Regulations. The sampled orders each impose Rs 5,00,000 under section 15HA, except one that abates because the noticee had died.

The record

What was ordered

Civil penalty

—

Disgorgement

—

Prejudgment interest

—

Total relief

—

Alleged gain

—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

This record groups 368 separate SEBI adjudication orders published between 2022-01-04 and 2022-12-30, each issued by an adjudicating officer to one noticee (or a small group) in the matter of dealings in illiquid stock options at BSE. It is read from a sample of orders, not from all 368; the individual noticees beyond the sample are not named here.

SEBI's investigation covered stock options trading on BSE between April 2014 and September 2015. It found that most trades in that segment, roughly 2.9 lakh trades or more than 81 percent, were reversals: a client bought or sold a contract and then took the opposite position with the same counterparty on the same day, often at prices that differed sharply. SEBI treated these trades as non-genuine because ownership did not meaningfully change hands, and said they inflated reported volume in contracts that otherwise barely traded. The investigation identified about 14,720 entities that executed such trades, and each was pursued in a separate adjudication proceeding.

In each order SEBI alleged that the noticee's trades created a false or misleading appearance of trading and breached Regulations 3(a) to (d), 4(1) and 4(2)(a) of the PFUTP Regulations 2003, and the adjudicating officer, after a show cause notice and a hearing opportunity, found the violation proved and penalised the noticee under section 15HA of the SEBI Act. Several of the later orders note that the noticee had first been offered SEBI's settlement scheme. Three sampled orders each impose a penalty on a single noticee: Arjun Sahoo HUF (order of 8 April 2022; the show cause notice alleged 3 reversal trades in one contract creating 10,08,000 units of artificial volume), Suman Poddar (16 March 2022; one contract, 24,000 units) and Kalpana Agarwala (17 February 2022; 48,000 units). A fourth sampled order, concerning the late Shiv Narain Agarwal (30 December 2022), disposes of the proceeding because the noticee had died, and imposes nothing.

In every sampled order that reaches the merits the adjudicating officer imposed Rs 5,00,000 under section 15HA of the SEBI Act, the statutory minimum for a fraudulent or unfair trade practice. The range across the samples is therefore nil (the abated proceeding) to Rs 5,00,000. Arjun Sahoo HUF denied the allegations at its hearing; the order nonetheless finds the trades non-genuine. The record does not show whether larger or smaller penalties appear in the other orders of the year.

The record does not show the outcome of any appeal to the Securities Appellate Tribunal, whether penalties were paid, the profit or loss of any noticee, or the circumstances of noticees outside the sample. Because the penalties are set by statute for each noticee, no total for the batch is stated here.

This library tags the batch as matched orders, because the conduct found was pre-arranged reversal trades between the same parties. The tagging is ours, not the regulator's.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the order.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Matched orders — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2022-01-04 First order of the year in the batch published
2. 2022-12-30 Last order of the year in the batch published (368 orders in 2022)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• First order in the batch (SEBI order page)
• Last order in the batch (SEBI order page)
• SEBI adjudication orders listing

The linked release is published by the issuing regulator under its own terms. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added October 8, 2026. submit a correction.